Is there a four-year deadline for Transactions in Securities counteraction notices?
6th March 2026
Posted in Articles by Andrew Marr
Transactions in securities legislation (‘TISL’) is anti-avoidance legislation whereby in certain circumstances HMRC can stop a taxpayer taxing themselves on a…
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Angels and demons and the perils of getting the EIS ‘directors’ rules’ wrong
27th February 2026
Posted in Articles by Andrew Marr
The Enterprise Investment Scheme (‘EIS’) offers various tax incentives to individuals who invest in start-up companies, including a 30% income tax…
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How 10 years fly by with EMI
20th February 2026
Posted in Articles by Adam Sutton
Enterprise Management Incentive (‘EMI’) schemes are specifically designed for private trading companies who wish to recruit and retain key employees. They…
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How a demolition job can lose your PPR
13th February 2026
Posted in Articles by Andrew Marr
Most property developers are conscious of the fact that stamp duty land tax (SDLT) rates are lower for bare pieces of…
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Tax mysteries surrounding distributions from companies limited by guarantee
30th January 2026
Posted in Articles by Andrew Marr
Companies which are limited by guarantee do not have shareholders and instead have members who act as guarantors. These kinds of…
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How are PETs taxed when value falls?
23rd January 2026
Posted in Articles by Andrew Marr
A potentially exempt transfer (PET) is a gift that will ‘potentially’ be outside a donor’s estate for inheritance tax (IHT) purposes….
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Uncertainty around whether interest has a UK source
16th January 2026
Posted in Articles by Andrew Marr
There is tax legislation (ITA 2007 section 874) which dictates that tax needs to be withheld from certain interest payments (generally…
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How loans can deny the Substantial Shareholding Exemption (SSE)
9th January 2026
Posted in Articles by Forbes Dawson
The Substantial Shareholding Exemption (SSE) should generally apply to disposals by companies of trading subsidiaries if the shareholding is at least…
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Have inter-spouse transfers of business property been a waste of time?
5th December 2025
Posted in Articles, IHT by Andrew Marr
Last year the Government made the unpopular announcement that Business Property Relief (BPR) would be restricted so that an individual can…
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How married couples can take advantage of the ‘50%:50%’ rental property rule
21st November 2025
Posted in Articles by Forbes Dawson
It is fairly common for one spouse (or civil partner) to want to share the taxation of rental income with their…
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